Transfer Pricing

In today’s environment, transfer pricing cuts across all aspects of driving value in a business. It is a key strategic tool that must be managed and implemented effectively.

That’s where we come in. We do it right. With a combination of accountants, economists, and people schooled in business, we know how to work-out what drives value in a business and then put a price on it.

Our team of transfer pricing specialists brings a wealth of in-house, advisory, and tax authority experience. We focus on strategy and planning, providing solutions that are insightful, robust, and pragmatic. Whether you are undertaking a business reorganisation, expanding into new markets, adopting new business models, have assets that need valued or integrating an acquisition, we have the right team for you. Oh, and we implement too, so with a team of lawyers standing behind us we can do all the legal stuff as well in offices all around the world.

No agenda. No baggage. Just good advice.

Representative experience

Advising Hitachi on compliance including provision of ongoing ad hoc transfer pricing support to Hitachi Europe Limited (EMEA’s HQ), including the performance of benchmarking searches as maybe required.

Advising TESCA on TP documentation for the group, with innovative fee structure for brokerage agreement; fee scale depending on profitability of the business generated by the head office for the subsidiaries; and audit defense in Slovakia.

Advising Columbia Threadneedle on a review of the effectiveness and sustainability of the Luxembourg feeder structure from a UK and Luxembourg tax perspective, including commenting on applicability of Luxembourg transfer pricing rules.

Advising A US Headquartered Retailer on its expansion into Europe, including the establishment of a European principal company and the migration of IP from the US to Europe and performing an IP valuation.

Advising a LATAM beverage company with operations in over 30 countries on a large-scale supply chain project involving strategic changes to its operating model, IP planning and setting-up an own-brand business under a more efficient structure.

Advising a European Fashion House on transfer pricing and duty implications of expanding its sourcing activity in Asia to take control over additional aspects of the supply chain.

Advising Worldwide business on supply chain optimization and the creation of a single hub to house IP, procurement and sales related activities for a business spanning multiple jurisdictions worldwide and over a hundred entities.

Advising Vodafone Group on providing expert reports in transfer pricing litigation in New Zealand regarding application of the arm’s length principle to credit rating analysis and loan pricing.

Advising PIMCO on the settlement of three tax assessment deeds issued by the Tax Authorities following a tax audit performed by the Tax Police and focused on the TP compliance of intragroup transactions.

Advising a household goods group on a strategic review of transfer pricing relating to procurement operations in Hong Kong and China, and advice on approach to settling a long-standing dispute.

Advising a global medical devices group on a significant number of complex valuations to support a restructuring of its supply chain and legal entity structure.

Advising an industrial equipment business on due diligence for the potential acquisition of numerous businesses in Asia. 

Advising BIA Foods on integrating various acquisitions for our global client as they expanded their business into the coffee sector. 

Advising Convatec on a significant number of complex valuations to support a restructuring of its supply chain and legal entity structure.

Advising a big data technology company on a valuation for tax purposes an intangible asset involving sensitivity analyses to address a lack of comparable market data.

Advising large digital economy business on settling a diverted profits tax investigation on favorable terms

Advising a number of Japanese parented groups to manage and defend their transfer pricing arrangements and rethink their business models.

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